If we were in Las Vegas, I would tell you to always bet on black. However, when it comes to dealing with United States Department of Treasury Office of Foreign Assets Control (“OFAC”) my advice is to always bet on Cuba. Once again OFAC has issued their monthly report on civil penalties and once again the majority of penalties relate to violations of the Cuban Assets Control Regulations.

Two entities, MGE UPS Systems, Inc. and First Incentive Travel, Inc., both received penalties for violations of the Cuban Assets Control Regulations. MGE UPS sold electronic regulators which were ultimately destined to Cuba. They provided $10,341 to settle the allegations against them. First Incentive Travel, Inc. was alleged to have provided travel related services in which Cuba had an interest. They settled those allegations for $8,250.

Two individuals were also penalized this month. While only one of them violated the Cuban Assets Control Regulations, they were still hit with a $15,000 penalty for engaging in financial transactions where Cuba or a Cuban national had an interest. The other individual was tagged with an $8,000 penalty for traveling to Iraq without an OFAC license in violation of the Iraq Sanctions Regulations.

It is interesting to see the number of travel related penalties. Normally, one does not take the procurement of an OFAC license into planning their vacations. However, given this new round of penalties maybe its time for travel service providers to seriously consider implementing an automatic OFAC licensing fee to travelers setting off for countries where OFAC has imposed travel restrictions. Just a thought. Maybe some already do this and I’m not aware. Please comment with your thoughts on this I would love to explore this area more.